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Minority interest, AT1 and T2 instruments qualifying for inclusion in consolidated own funds

How should the calculation in Article 85(1) CRR be performed “on a sub-consolidated basis for each subsidiary” as required by Article 85(2) CRR, where no sub-consolidation or sub-consolidated own funds requirements apply to an institution?

COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

ID: 2017_3567| Topic: Own funds| Date of submission: 20/10/2017

Transaction Risk Analysis (TRA) exemption – Time period for calculation of initial fraud rate

What is the relevant time period to use when calculating the initial fraud rate for use when the Strong Customer Authentication (SCA) comes into force?

COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication

ID: 2018_4044| Topic: Strong customer authentication and common and secure communication (incl. access)| Date of submission: 28/06/2018

Reporting the gross carrying amount of the credit-impaired financial assets measured at amortised cost (other than purchased or originated credit-impaired financial assets), in the context of the new FINREP framework, as provided for in the Regulation (EU) 2017/1443

Our question is whether the gross carrying amount of a credit-impaired financial asset measured at amortised cost (other than purchased or originated credit-impaired financial assets) reported in the column 040 of the template F 04.04.1 “Financial assets at amortised cost” should be: a) the principal amount together with the value of the interest computed in accordance with IFRS 9 5.4.1(b) (not the entire value of the contractual interest accrued). or b) the contractual amount of the principal and of the interest accrued according to the contractual terms; in this case, the value of the accumulated impairment for this financial asset presented in the template F 04.04.1 would include the adjustment of the contractual interest (to attain the value of the interest revenue computed in accordance with IFRS 9 5.4.1(b)).

COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (as amended)

ID: 2017_3553| Topic: Supervisory reporting| Date of submission: 11/10/2017

Location of the obligor for the calculation of the countercyclical capital buffer

What is the definition of “actual place of administration” in Article 1(4) of Regulation (EU) 1152/2014?

COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 1152/2014 - RTS on the identification of the geographical location of relevant credit exposures for institution-specific countercyclical capital buffer rate

ID: 2018_3739| Topic: Other topics| Date of submission: 27/02/2018

3 month notification period on interface changes to ASPSPs’ interfaces

Do account servicing payment service providers (ASPSPs) need to adhere to a 3 month notification period for all interface changes, or only for breaking interface changes, as specified in the RTS on on strong customer authentication (SCA) and secure communication (CSC) Article 30 Paragraph 4?  

COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication

ID: 2019_4823| Topic: Strong customer authentication and common and secure communication (incl. access)| Date of submission: 09/07/2019

Applicability of exemption under RTS Article 16 for payee’s PSPs (acquirers)

Can an exemption under Article 16 of the RTS on strong customer authentication and secure communication be applied by the payee’s payment service provider (PSP) (the acquirer) for card-based payments?

COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication

ID: 2018_4242| Topic: Strong customer authentication and common and secure communication (incl. access)| Date of submission: 06/09/2018

Applicability of exemption under RTS Article 11 for payee’s PSPs (acquirers)

Can an exemption under Article 11 of the RTS on strong customer authentication and secure communication be applied by the payee's payment service provider (PSP) (the acquirer) for card-based payments?

COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication

ID: 2018_4241| Topic: Strong customer authentication and common and secure communication (incl. access)| Date of submission: 06/09/2018

Contactless counting

For the purpose of counting previous cumulative contactless transactions in order to assess the eligibility of the exemption in Article 11 of the RTS, should contactless transactions initiated outside of the EEA be included?

COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication

ID: 2018_4227| Topic: Strong customer authentication and common and secure communication (incl. access)| Date of submission: 05/09/2018

Contactless payments at point of sale - Applications of the conditions

With respect to Article 11 Paragraph b) of the RTS can we setup control for either 150 € or 5 transactions?

COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication

ID: 2018_4225| Topic: Strong customer authentication and common and secure communication (incl. access)| Date of submission: 05/09/2018

Application of limits for Strong customer authentication (SCA) exemption

How should payment service providers (PSPs) apply the cumulative limits set in Articles 11 and 16 of the RTS on strong customer authentication and secure communication?

COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication

ID: 2018_4182| Topic: Strong customer authentication and common and secure communication (incl. access)| Date of submission: 06/08/2018

Application of the low-value contactless exemption – Calculation of limits at Primary Account Number (PAN) / account level or at device / token level

May the counters for the application of the low-value contactless exemption be calculated at device/token level?

COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication

ID: 2018_4036| Topic: Strong customer authentication and common and secure communication (incl. access)| Date of submission: 28/06/2018

Criteria for the application of the transaction risk analysis (TRA) exemption – Relevant fraud rates

Is only the Payment Service Provider (PSP) applying the TRA exemption required to have a fraud level below the reference fraud rate?

COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication

ID: 2018_4034| Topic: Strong customer authentication and common and secure communication (incl. access)| Date of submission: 28/06/2018

F35.00 Covered Bonds - FX rates to be applied

There are circumstances where the covered bond has been issued in one currency and the underlying assets are in a different currency. In which case, the covered bond programme would hedge this cross currency risk. In this circumstance, which FX rate should be applied? The spot FX rate as per the reporting date or the strike FX rate as per the swap agreement?

COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (as amended)

ID: 2015_2270| Topic: Supervisory reporting| Date of submission: 04/09/2015

F35.00 Covered Bonds reporting of over collaterization

In Rows 020 and 030, Columns 220-250, are UK banks required to complete these cells if over collateralisation is determined on a nominal basis as per UK covered bond regulations?  If so, how should over collateralization be translated into Present Value (what discount rate should be applied) or how should we determine the Asset Specific Value?

COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (as amended)

ID: 2015_2269| Topic: Supervisory reporting| Date of submission: 04/09/2015

Row asset-backed securities in Asset encumbrance templates

Can you please make the row 060 'asset-backed securities' in table F 32.01 consistent with the Annex XVII (reporting on asset encumbrance) page 10 'of which: securitisations'? Same applies to row 180 in F 32.02.

COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (as amended)

ID: 2015_1999| Topic: Supervisory reporting| Date of submission: 09/05/2015

Realization of developers' collaterals and re-classification of developers into performing status

Clarifications are requested surrounding the classification of a borrower into default status and therefore into non-performing status, when the borrower is a developer / construction company and hence relies on the realisation of collaterals to repay his loans.

COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (as amended)

ID: 2018_3747| Topic: Supervisory reporting| Date of submission: 05/03/2018

Reporting of the interest income and interest expense from hedging derivatives

Our question is in which item of template F 02.00 (FINREP IFRS 9) interest income and interest expense from hedging derivatives classified in the category ”hedge accounting” should be reported, where: the hedging derivatives are used to hedge interest rate risk and are measured at fair value through profit or loss; the dirty price approach is the convention applied by the credit institution; and the hedged instrument is not measured at fair value through profit or loss (i.e. the hedged instrument is a debt financial instrument whose interest is recognized as “interest income” or “interest expense” in the statement of profit or loss).

COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (as amended)

ID: 2017_3601| Topic: Supervisory reporting| Date of submission: 23/11/2017

Template F 16.04 line row 070 – relevance for nGAAP

In Annex IV (Financial Reporting for National GAAP based on BAD) of Commission Implementing Regulation (EU) No 680/214 in template F 16.04 excel the row line 070 ”Gains or losses on Financial assets and liabilities held for trading” is not black, while this cell is an IFRS cell. Is it an error?

COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (as amended)

ID: 2017_3578| Topic: Supervisory reporting| Date of submission: 31/10/2017

Reporting of transfer between capital surplus (share premium) and retained earnings in FINREP F 46 template.

Under the Hungarian legislation negative balance of retained earnings could be offset by a transfer from other elements of own funds. If such transaction occurs how should it be reported in template F46?

COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (as amended)

ID: 2017_3504| Topic: Supervisory reporting| Date of submission: 31/08/2017

FINREP Template F20.04 (r210,r230)

Template F 20.04, row 210 reports ”Non-financial corporations – Of which: Loans collateralized by commercial immovable property”. However, in Hong Kong there could be non-financial corporations (NFC) borrowing loans that are collateralized solely by ”Residential immovable property” rather than by “Commercial immovable property”. For this case, should the corresponding loan amount be reported in row 230? Similarly, should household (HH) borrowing loans that are collateralized solely by ”Commercial immovable property” require to be reported in row 230, “Households – Of which: Loans collateralized by residential immovable property”?

COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (as amended)

ID: 2017_3486| Topic: Supervisory reporting| Date of submission: 23/08/2017

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